I think the broad distinction, as I mentioned very briefly earlier on, is between the Scandinavian countries and the others.
I think the Scandinavian countries, as you say, it's a much higher -- the starting point is a thou shalt not, that you start from a position where you do not infringe privacy unless there's an overriding public interest.
Whereas in the countries I looked at -- Ireland and Australia and Germany -- there's a different approach. It's more of a sort of balancing act approach, as it were.
In terms of the public interest, although it's mentioned in each of the codes, it's only in Ireland and in Australia that they, as it were, have a stab at defining it. You heard the principle from Professor Horgan this morning, and essentially Australia does the same thing.
But it seems to me what they do actually is to substitute "legitimate". They say it's a legitimate interest. I think they all look on a case-by-case basis at the public interest.